The Focus and Scope of This Information

This page provides information focusing on the Design for Recycling rules under the Packaging and Packaging Waste Regulation (PPWR, (EU) 2025/40), the technical performance classes of packaging, and the implementation timetable for recycled content targets.

Service note: AES Innovation carries out the EU compliance work described on this page (PPWR, digital product passport, CBAM, etc.) in collaboration with expert solution partners; it does not provide these services directly. These activities are outside the scope of our accreditation (EU-0631-M).

The general definition of PPWR and its impact on Turkish exporters are discussed in detail in our other related content. Here, without going into a general definition, we will focus directly on the design criteria and the phased implementation architecture of the legislation.

  • PPWR (EU) 2025/40: published 22 January 2025, entered into force 11 February 2025.
  • The general application date is 12 August 2026; on this date, Directive 94/62/EC will cease to be in effect.
  • The August 12, 2026 deadline does not cover all requirements; many obligations will come into effect gradually.
  • This content focuses solely on technical design criteria and the timeline.

Recyclability Performance Classes: A, B, and C

PPWR proposes a rating system that categorizes packaging into performance classes based on its degree of recyclability. This system links the packaging's suitability for recycling to a measurable criterion from the design stage onwards.

The grading is done across three classes: Grade A means the packaging is at least 95% recyclable; Grade B, at least 80%; and Grade C, at least 70%. Below 70% is considered technically non-recyclable, and packaging in this condition cannot be placed on the market.

The broader letter scale occasionally discussed in public discourse has not been consistently validated; therefore, only A, B, and C should be considered as official classes, and anything below 70 percent should be treated as a non-recyclable band, not a separate official class. The final evaluation methodology for class calculation will be determined by delegated act.

  • Grade A: at least 95 percent recyclable.
  • Grade B: at least 80 percent recyclable.
  • Grade C: at least 70 percent recyclable.
  • Below 70 percent: technically considered non-recyclable and cannot be put on the market.
  • Only A/B/C are official grades; a wider letter scale has not been validated.

Schedule for the implementation of the classes: 2030, 2035, and 2038

Performance-based grading will become binding not in a single step, but through a phased schedule. The mandatory start of grading is projected for January 1, 2030.

In 2035, an additional threshold is expected to be introduced, requiring packaging to be evaluated according to its recycled at scale. By 2038, Grade C packaging is projected to be phased out of the market, leaving only Grade A and Grade B packaging available.

The practical dates for this calendar depend on the delegated act formula described below, and the featured dates may shift if the relevant act is delayed.

  • January 1, 2030: Mandatory start of grading.
  • 2035: An additional recycling threshold is expected to be introduced at this scale.
  • 2038: Grade C is discontinued, leaving only Grade A and B.
  • Practical dates depend on the enactment of the delegated act and may shift.

Recycled Content (PCR) Targets

PPWR sets minimum percentages for post-consumer recycled content (PCR) used in plastic packaging, varying by product group. These targets are planned to be effective from January 1, 2030, and are expected to be raised with a second threshold in 2040.

The following ratios are values in the plan. Exemptions apply for compostable packaging and certain contact-sensitive applications. Both the exemptions and the final methodology for calculating the content will be finalized depending on the relevant implementing/delegated acts.

  • PET packaging in contact with food: 30%, 50% in 2040.
  • Non-PET, contact-sensitive plastics: 10 percent, 25 percent by 2040.
  • Single-use plastic beverage bottles: 30 percent, 65 percent by 2040.
  • Other general plastic packaging: 35 percent, 65 percent in 2040.
  • There are exemptions for compostable and certain contact-sensitive packaging.
  • Final rates and calculation methodology depend on the relevant acts.

Delegated and Implementing Act Schedule: A Critical Point for the Turkish Supply Chain

The core text of the PPWR establishes the framework; however, the technical details of the class criteria and content accounts will be determined by secondary legislation (delegated and implementing act). This timeline directly affects when the legislation becomes effectively binding.

Two key implementing acts that the Commission is expected to issue by December 31, 2026, stand out: methodology for calculating and verifying recycled content, and equivalence rules for recycled plastics from outside the European Union (third countries). This second act is critical for the supply chains of non-EU recyclers, such as Turkey, and presents both direct risks and opportunities.

The Design-for-Recycling delegated act, which will define the recyclability assessment methodology and class criteria, is expected to be adopted by January 1, 2028. The binding date for grading and content objectives depends on the formula: in most cases, January 1, 2030, or 24 months after the relevant delegated act comes into effect, whichever is later. Therefore, if the act is delayed, the practical effective date may shift.

  • By December 31, 2026: implementing the recycled content calculation/validation methodology act.
  • By December 31, 2026: Equivalence rules for non-EU recycled plastics (critical for the Turkish supply chain).
  • By January 1, 2028: Design-for-Recycling delegated act (assessment methodology and class criteria).
  • Binding formula: 1 January 2030 or 24 months after the delegated act comes into effect, whichever is later.
  • If the Act is delayed, the practical deadlines may shift forward, not forward.

Other Key Dates from a Design Perspective and Their Practical Impact on the Turkish Manufacturer

In addition to recyclability and content objectives, there are other dates that affect design and documentation. These topics are discussed in detail in our other related content and are only briefly mentioned here in the context of design.

PPWR (Protected Packaging Warranty) is not based on origin, but on entry into the European Union market; therefore, every packaged product destined for the Union is covered. Although the majority of the obligation legally rests with the importer in the Union, in practice, the design of harmonized packaging and the preparation of the technical file fall to the manufacturer, and buyers in the Union are increasingly making this a contractual requirement. Therefore, issues such as mono-material design, selection of PFAS-free materials for food contact, recycled content supply chain, reduction of empty space, and labeling and documentation should be addressed early on. Obtaining support from qualified engineers for the technical verification of design decisions contributes to the smooth progress of the process.

  • Approximately August 12, 2028: harmonized labeling.
  • February 12, 2029: Reusability mark.
  • January 1, 2030: maximum 50% free space and Annex-V bans on single-use items.
  • Design focuses: mono-material, PFAS-free food contact, PCR supply, space reduction, labeling, and documentation.
  • Non-EU recycler equivalence (December 31, 2026) represents both a direct risk and an opportunity for the Turkish supply chain.

Information Note

This content is for informational purposes only. AES is not an approved body or certification body; it does not issue packaging conformity certificates, recyclability verifications, or certificates.

AES's TÜRKAK accreditation is only within the scope of 6.1 Electrical Installation inspection. The recyclability assessment and suitability of the packaging are determined by the relevant delegated acts and authorized bodies. The dates and rates here are based on the values in the plan, and the final methodology and exemptions will be clarified with the finalization of secondary legislation.

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Frequently Asked Questions

What are the PPWR recyclability performance classes?

Packaging is classified according to its degree of recyclability as Grade A (at least 95 percent), Grade B (at least 80 percent), and Grade C (at least 70 percent). A grade below 70 percent is considered technically non-recyclable and cannot be placed on the market. The official grades are only A, B, and C.

When do classes become compulsory?

The mandatory start of the grading system is projected for January 1, 2030. The introduction of an additional recycling threshold at scale is expected in 2035, and Grade C is expected to be phased out in 2038, leaving only Grade A and B. These dates may shift depending on the implementation of the delegated act.

What are the targets of recycled content (PCR)?

From January 1, 2030, rates are planned as follows: 30% for food contact PET, 10% for non-PET contact-sensitive plastics, 30% for single-use plastic beverage bottles, and 35% for other general plastics; these rates are increasing in 2040. Exemptions and the final calculation methodology depend on the relevant acts.

What is the most critical calendar item for Turkish recyclers?

The Commission's implementing act on equivalence rules for recycled plastics from outside the European Union, expected to be released by December 31, 2026, creates direct risks and opportunities for the Turkish supply chain that produces outside the EU. These rules will affect whether recycled content from Turkish sources will be counted towards the targets.

Why are the binding dates not precise?

The binding date for grading and content objectives is, in most cases, based on the formula of 1 January 2030 or 24 months after the relevant delegated act comes into effect, whichever is later. The Design-for-Recycling delegated act is expected to be adopted by 1 January 2028, and in case of delay, practical entry into force may be pushed back.

Does AES issue recyclability certificates for packaging?

No. AES is not an approved body or certification body and does not issue packaging conformity certificates, recyclability verifications, or certificates. AES's TÜRKAK accreditation is only for section 6.1 Electrical Installation inspection. This content is for informational purposes only.